88wine Privacy Policy — Your Data, Our Responsibility

1.Data Controller

1.1  For the purposes of this Privacy Policy, the data controller responsible for your personal information is 88wine, operating the platform at 88wine.pro under an international gaming licence. References to "88wine", "we", "us" or "our" throughout this policy refer to the same entity.

1.2  88wine is the sole data controller in respect of personal data collected through the registration process, the 88wine login interface, financial transactions, customer support interactions and all other touchpoints on the platform. We determine the purposes and means of processing your personal data and are responsible for ensuring that such processing is conducted lawfully and transparently.

1.3  For all privacy-related enquiries, including requests to exercise your data rights, you may contact our dedicated privacy team at [email protected]. We aim to acknowledge all privacy requests within five (5) business days.

2.Data We Collect

2.1  88wine collects personal data in several categories. The table below summarises the main categories of data collected and the context in which each category arises:

2.2  88wine does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data, except where expressly required by applicable law or where you voluntarily disclose such information in the context of a responsible gaming self-assessment.

3.How We Collect Your Data

3.1  Directly from you. The majority of the personal data 88wine holds about you is provided directly by you at specific points in your relationship with the platform:

• When you complete the 88wine registration form and create your account.
• When you submit KYC documentation to verify your identity and age before withdrawal.
• When you make a deposit or request a withdrawal via JazzCash, EasyPaisa, HBL, UBL or Meezan Bank.
• When you contact 88wine customer support via live chat or email.
• When you respond to surveys, promotions or feedback requests issued by 88wine.
• When you configure responsible gaming tools such as deposit limits or self-exclusion from within your account settings.

3.2  Automatically. When you access the 88wine platform — whether via desktop browser or mobile device — our systems automatically collect certain technical and usage data. This includes your IP address, device identifiers, browser fingerprint, pages and games accessed, duration of sessions and the outcomes of wagers placed. This data is collected using server logs, cookies and similar tracking technologies described in Section 6.

3.3  From third parties. In limited circumstances, 88wine may receive personal data about you from third parties. This includes identity and fraud verification data from KYC service providers, payment confirmation data from Pakistani payment processors (JazzCash, EasyPaisa, HBL, UBL and Meezan Bank), and where applicable, data from responsible gaming databases used to verify self-exclusion status.

4.Purpose & Legal Basis for Processing

4.1  88wine processes your personal data for the following purposes, each supported by a corresponding legal basis:

• Account creation and management — processing is necessary for the performance of the contract between you and 88wine.
• Processing deposits and withdrawals in PKR — processing is necessary for the performance of the contract and for compliance with financial regulations applicable to 88wine's gaming licence.
• KYC identity and age verification — processing is required by legal obligation to prevent underage gambling and money laundering.
• Fraud prevention and platform security — processing is in 88wine's legitimate interests to protect the platform and all players from abuse and financial crime.
• Customer support — processing is necessary for the performance of the contract and for 88wine's legitimate interest in resolving player queries effectively.
• Responsible gaming compliance — processing is required by legal obligation under the platform's international gaming licence to identify and support at-risk players.
• Marketing and promotional communications — processing is based on your consent, provided during registration or subsequently updated in your account preferences. You may withdraw consent at any time.
• Platform improvement and analytics — processing is in 88wine's legitimate interest to optimise the platform for Pakistani players and improve game and product offerings.

5.Data Sharing & Disclosure

5.1  88wine does not sell, rent, or trade your personal data. We share your data only in the circumstances described below and only to the extent necessary for the stated purpose:

• Payment processors: We share necessary transaction data with Pakistani payment service providers (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) to execute deposits and withdrawals. These providers act as data processors under contractual obligations to 88wine.
• KYC and identity verification providers: We share identity documents and associated data with certified KYC verification partners to satisfy our age verification and anti-money laundering obligations under the platform's gaming licence.
• Fraud prevention and security services: We share technical data (IP addresses, device identifiers, behavioural patterns) with fraud detection service providers to identify and prevent suspicious activity on the platform.
• Responsible gaming databases: Where required, we share data with responsible gaming registries to cross-check self-exclusion status and prevent excluded players from accessing the platform.
• Legal and regulatory authorities: We disclose personal data to competent authorities where required by applicable law, court order, or instruction from a regulatory body with jurisdiction over 88wine's operations.
• Platform technology providers: We share limited operational data with hosting, cloud infrastructure, and analytics providers who process data on our behalf under data processing agreements with security and confidentiality obligations.

5.2  All third parties with whom 88wine shares personal data are required to process that data in accordance with applicable data protection standards and solely for the purposes specified by 88wine. 88wine does not permit any third party to use your personal data for their own independent marketing purposes.

6.Cookies & Tracking Technologies

6.1  88wine uses cookies and similar tracking technologies (including web beacons and session storage) to operate the platform, maintain your logged-in session, remember your preferences and analyse usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in during your 88wine session. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display options and responsible gaming tool configurations. These improve your experience but are not essential.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate the platform — which games are visited most, how long sessions last, and where players encounter issues. This data helps 88wine improve platform performance.
• Security Cookies: Used to support fraud detection by identifying unusual patterns of access, such as logins from unrecognised devices or IP addresses inconsistent with a player's typical location in Pakistan.

6.2  On your first visit to 88wine.pro, a cookie consent notice will be displayed. You may accept all cookies, accept only strictly necessary cookies, or manage your preferences in detail. Withdrawing cookie consent for non-essential categories will not affect your ability to use the platform's core features.

6.3  Most browsers allow you to view and delete cookies stored on your device via your browser's privacy or settings menu. Note that clearing strictly necessary cookies will log you out of your current 88wine session.

7.Data Retention

7.1  88wine retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to resolve disputes or enforce our agreements. The following general retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in accordance with anti-money laundering obligations applicable under 88wine's international gaming licence.
• Financial transaction data: Retained for a minimum of seven (7) years to satisfy financial record-keeping requirements.
• KYC documents: Retained for five (5) years from the date of submission or the date of account closure, whichever is later.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless the communication relates to an ongoing dispute, in which case it is retained until the dispute is resolved.
• Marketing preferences and consent records: Retained for the lifetime of your account and for two (2) years following account closure as evidence of consent status.
• Technical and usage data (logs): Typically retained for 90 days in an identifiable form, after which data is aggregated and anonymised for analytical purposes.

7.2  Where data is no longer required for any lawful purpose, 88wine applies secure deletion procedures to ensure that personal data is irreversibly removed from our systems and those of our data processors.

8.Data Security

8.1  88wine implements a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration or destruction. Our security measures include:

• TLS/SSL encryption for all data in transit between your device and 88wine servers.
• AES-256 encryption for sensitive personal and financial data at rest in our databases.
• Role-based access controls ensuring that only authorised personnel with a documented operational need can access player personal data.
• Regular security audits, penetration testing and vulnerability assessments conducted by qualified security professionals.
• Two-factor authentication for all internal administrative access to systems containing player data.
• Real-time intrusion detection and anomaly monitoring on all production systems.

8.2  While 88wine takes all reasonable technical and organisational measures to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 88wine login credentials and must notify us immediately at [email protected] if you suspect that your account has been accessed without your authorisation.

8.3  In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, 88wine will notify affected individuals without undue delay and will take all necessary steps to contain and remediate the breach.

9.Your Data Rights

9.1  As a registered 88wine player, you have the following rights in relation to your personal data. These rights are subject to applicable legal limitations and may be exercised by contacting [email protected]:

9.2  88wine will respond to all data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further two months, in which case we will notify you of the extension and the reason within the initial 30-day period. We may request proof of identity before processing a data rights request to protect against unauthorised access to another person's data.

10.Children's Privacy

10.1  The 88wine platform is strictly intended for adults aged 21 and above. We do not knowingly collect, store or process personal data from any individual under the age of 21. Age verification is conducted as a mandatory step before any withdrawal is processed, and 88wine reserves the right to require KYC documentation at any stage of the account lifecycle.

10.2  If 88wine becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and permanently close the associated account. Any funds held in such an account will be handled in accordance with applicable legal requirements.

10.3  If you are a parent or guardian and believe that your child has registered an account with 88wine, please contact us immediately at [email protected] so that we can investigate and act without delay.

11.International Data Transfers

11.1  As an online platform operating under an international gaming licence, 88wine may transfer personal data to servers and service providers located outside of Pakistan. Such transfers occur in connection with our hosting infrastructure, KYC verification partners and fraud prevention service providers.

11.2  Where personal data is transferred internationally, 88wine ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that applied within Pakistan. These safeguards include contractual data protection clauses binding recipient parties to privacy and security obligations consistent with those described in this policy.

11.3  By using the 88wine platform and completing the 88wine login process, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Pakistan for the purposes described in this policy, subject at all times to the safeguards described above.

12.Changes to This Privacy Policy

12.1  88wine reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform operations. Material changes will be communicated to registered players via the email address on file or via a prominent notice on the 88wine platform prior to the effective date of the change.

12.2  The date of the most recent update is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to remain informed about how 88wine protects your personal information. Your continued use of the platform following notification of changes constitutes acceptance of the revised Privacy Policy.

12.3  Where a proposed change materially affects the basis on which we process your personal data in a way that requires fresh consent, we will request your explicit agreement before applying the change to your account.

13.Contact Us — Privacy Enquiries

13.1  All privacy-related enquiries, data rights requests, and concerns regarding 88wine's handling of your personal information should be directed to our support team. We have a dedicated privacy review process to ensure that all such requests are handled appropriately and within the timeframes stated in this policy.

13.2  When submitting a privacy request, please include your registered 88wine account email address, your full name as registered, and a clear description of your request. This will allow us to locate your records and process your request as efficiently as possible. For security purposes, we may require you to verify your identity before acting on your request.

13.3  If you are dissatisfied with 88wine's response to a privacy request or complaint, you have the right to escalate your concern to the relevant data protection authority or regulatory body in your jurisdiction.